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The Division is inviting testimony regarding Arc Fault Circuit Interrupters (AFCI). The Division

is requesting the following specific information. The information will be used to assess the

upcoming expansion of AFCI protection beyond residential bedrooms to other living areas.

1. How many states have adopted, without modification, the AFCI requirements in the

2008 or later NEC?

Out of 50 states and the District of Columbia, 35 states have adopted the expanded

requirements of AFCI that NEC 2008 introduced and NEC 2011 continues to require.

There are 5 states that have made a conscious decision to keep AFCIs to the language of

NEC 2005 which kept AFCIs on bedroom circuits only. There are approximately 9 states

that do not have a state wide adoption. There is one state that has made a conscious

decision to not have any AFCI requirements for new structures built in that state.

The following states have reviewed and adopted NEC 2011. The table includes

amendments specific to AFCIs as well as the effective dates.

STATE AMENDMENTS EFFECTIVE

DATE

Massachusetts None 1/1/2011

North Dakota Branch Feeder AFCIs are Permitted 9/1/2011

Minnesota None 8/1/2011

South Dakota None 7/1/2011

Nebraska None 8/27/2011

Vermont None 6/1/2011

Rhode Island None 8/1/2011

New Hampshire None 7/1/2011

Maine None 7/19/2011

Texas None 9/1/2011

Utah None 7/1/2012

Nevada None

Iowa None 1/1/2012

Colorado None 7/1/2011

Kentucky None 1/1/2012

Wyoming None 7/1/2011

Ohio None

11/1/2011 - Multi-Family, commercial,

industrial

1/1/2013 - Residential

Alabama None 4/18/2011

New Mexico None 11/1/2011

Georgia None 1/1/2012

New Jersey Section 210.12(B) Branch Circuit Extensions or

Modifications Dwelling Units deleted because it is regulated by the Rehabilitation Sub-code

5/7/2012

Arkansas None 1/1/2012

North Carolina None 7/3/2012

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The following states have reviewed and adopted NEC 2008. The table includes

amendments specific to AFCIs as well as the effective dates.

STATE AMENDMENTS EFFECTIVE

DATE

Virginia Bedrooms Only 3/1/2011

New York None 7/1/2011 (NY City)

Idaho Bedrooms Only 4/1/2012

Hawaii None 4/16/2010

South Carolina Smoke Detectors Not Required to be AFCI Protected 7/1/2009

Wisconsin None 1/1/2010

Montana None 7/30/2010

Tennessee Bedrooms Only 1/28/2009

Louisiana None 1/1/2010

Indiana 210.12 removed No AFCI requirement 8/26/2009

Michigan Bedrooms only 12/2/2009

Pennsylvania None 12/31/2009

Alaska None 1/1/2009

Florida None 8/1/2009

Delaware Smoke Detectors Not Required to be AFCI Protected 11/11/2009

Washington Smoke Detectors Not Required to be AFCI Protected &

Bedrooms Only 12/31/2008

West Virginia None 7/1/2010

California None 1/1/2011

2. What are the demonstrated safety benefits of AFCI protection? (i.e. number of

preventable fires related to the lack of AFCI devices, loss of life or property

traceable to fires caused by arcing, etc.)

The “Oregon Fire Fatality Review 2004 – 2008” report illustrates the following statistics

for the state of Oregon:

These four top causes of fatal fires account for 79% of the fatalities5: 46% cigarette, cigar, or pipe (includes 8% smoking while on oxygen) 13% candle 11% electrical 9% combustibles too close to heat source

These three rooms where the fire started account for 80% of the fatalities: 41% in the living room or family room 30% in the bedroom 10% in the kitchen

Oregon incurred more than $59Million in property damage due to structure fires, not just

electrical fires, in one and two family dwellings in 2009. There were 172 Injuries and 9

deaths in all for 2009. 14% of these fires, equating to 269 incidents, are classified as

having an ignition source due to an electrical arc or overload. This is specific to structure

fires in one and two family dwelling units and for 2009 alone.

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The AFCI product is designed to help mitigate these types of electrical fires that cost

states like Oregon lives and property damage. AFCIs can help decrease the loss in lives

and property.

FEMA reports, from a national perspective, a decline in residential building electrical

malfunction fires over a 5 year period from 2006 to 2010. Their data illustrates the

following:

An 18% decrease in fires.

A 4% decrease in deaths.

A 3% increase in injuries.

A 3% decrease in dollar loss. (Note: This overall constant dollar loss trend takes

inflation into account by adjusting each year’s dollar loss to its equivalent 2010

value.)

These statistics illustrate the value of the national electrical code as well as timely

adoption and enforcement of building codes in general. This activity saves lives and

property reducing the financial impact of electrical fires which are very devastating as

these types of fires result in severe negative impact to the structure.

Figure 1 - Electrical Malfunction Fires – NFPA

Figure 1 displays the number of fires decreasing since AFCIs were introduced into the

code to the most current data.1

Electrical Malfunction Fires - NFPA

35000

40000

45000

50000

55000

60000

2002 2003 2004 2005 2006 2007 2008 2009

Year

Fir

es

4

Figure 2 - Electrical Distribution Fires – NFPA

Figure 2 shows similar information to Figure 1 above.

Since 2008, the year that NEC 2008 expanded AFCIs to branch circuits supplying other

areas of the home in addition to bedroom circuits, the number of electrical distribution

and lighting equipment fires has steadily decreased. Key findings in this study showed

that wiring or related equipment was the highest cause of home fires, followed by lamps,

light fixtures, cords, and plugs.2 The NFPA recommends keeping the house updated with

the most current codes.

3. Where there are reports of AFCI device tripping, what was determined to be the cause?

(i.e. faulty wiring or post-wiring puncture, specific wiring methods, specific pieces of

equipment/products, etc.)

Attached is a document illustrating examples of the AFCI products finding damaged

wiring and damaged appliances due to many different causes. There is also a video on

You Tube that documents one particular home owner who experienced tripping of his

AFCIs and was told numerous times to replace the AFCIs with standard thermal

magnetic circuit breakers. Part 1: http://www.youtube.com/watch?v=fO5ulBRdVb8&feature=youtube_gdata_player

Part 2: http://www.youtube.com/watch?v=97mgZw-ZrDY&feature=youtube_gdata_player

Part 3: http://www.youtube.com/watch?v=XBqm3TTVPlA&feature=youtube_gdata_player

Part 4: http://www.youtube.com/watch?v=VLOgTrSM3XE&feature=youtube_gdata_player

Part 5: http://www.youtube.com/watch?v=iirOIwePOYA&feature=youtube_gdata_player

Attached is this home owners thank you letter after he worked together with the

manufacturer and electrical contractor to find and fix the cause of the tripping - a

damaged conductor.

Electrical Distribution Fires - NFPA

0

5000

10000

15000

20000

25000

30000

2006 2007 2008 2009 2010

Year

Fir

es

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4. What are the costs of complying with the requirements for installing AFCI protecting in

living areas? (i.e. cost of device(s), average cost of call backs, etc.)

The cost of not employing this technology is reflected in the fire statistics illustrated

above.

The AFCI circuit breaker takes no more time to install than a standard thermal magnetic

circuit breaker. The cost of an AFCI circuit breaker varies by manufacturer and

arrangement with the electrical contractor. Lowes on line shows prices of AFCIs to be

approximately $35 - $40 per breaker.

The National Electrical Code only requires AFCI protection for 15- and 20-ampere

branch circuits supplying outlets installed in dwelling unit family rooms, dining rooms,

living rooms, parlors, libraries, dens, bedrooms, sunrooms, recreation rooms, closets,

hallways, or similar rooms or areas. According to the Electrical Construction and

Maintenance newsletter3, the average number of AFCIs needed in a home is 12 devices.

This would equate to $480 per home. The U.S. Census and the U.S. Department of

Housing and Urban Development released the median sale price of a new house sold in

May 2012 of $234,500.004. The additional cost of around 0.2% of the total cost of the

house is an insignificant price for increased levels of safety provided by installed AFCIs.

5. Are you aware of instances where a homeowner has tried to by-pass the device?

Unfortunately the bypassing of this technology is typically performed more by the

electrical contractor than the home owner. The case example mentioned above illustrates

the electrical contractor wanting to replace the AFCI breaker with a standard thermal

magnetic circuit breaker which is one way to bypass the technology. It is the only

documented case of this activity to date. Anecdotal examples are available but not

reliable.

Another way to bypass the technology is by the use of extension cords to operate

equipment that may appear to be tripping the AFCI. This activity is usually a temporary

activity until the problem is found and the circuit again operates effectively. Thermal

magnetic circuit breakers cannot find problems in connected appliances and so this

equipment appears to operating without problem until investigated. There are two

documented cases of AFCIs finding appliance and fixture problems. One of these two

examples resulted in a CPSC recall of the product in question. They are included in the

examples attached to this document. The CPSC recall can be located at the following

URL: http://www.cpsc.gov/cpscpub/prerel/prhtml12/12197.html

1. J. Hall. “Home Electrical Fires” National Fire Protection Association Fire Analysis and

Research Division, Jan. 2012.

2. “Home Fires Involving Electrical Distribution and Lighting Equipment – 2010” National

Fire Protection Association, Jan. 2012.

3. G. Winstanley. “Arc Fault Detection: Your Questions Answered” Electrical Construction and

Maintenance Magazine, November 1, 2007

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CUSTOMER THANK YOU LETTER

Page 1 of 2

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CUSTOMER THANK YOU LETTER

Page 2 of 2

80 years of excellence

Arc Fault Circuit Interrupter

Found Problems

80 years of excellence

AFCI’s avert potential disaster in South Carolina “I would like to take the time and thank you for the Arc Fault breaker, your product saved our lives and our home.”

•Homeowner built house in 2005; experienced AFCI Tripping

•Advised to replace AFCI’s with Standard Breakers

•Homeowner worked with the manufacturer and a contractor

to locate the problem

•Electrical contractor located arcing in the home run circuit

•During troubleshooting, gas leaks found in the vicinity of

the damaged conductors

•The wire was shredded due to being pulled through a jagged

hole drilled in a gusset plate

•AFCI Breaker averted disaster

“So, because the AFCI breaker was doing it’s job, its

relentless and nerve racking tripping saved my family’s life

(myself, my wife, and 2 daughters) both from fire and from

gas explosion since I had an arcing wire and a gas leak! Not

to mention saving my home and its valuable contents. Thank

you very much for the Arc Fault breaker. It did its job and

saved our lives.”

80 years of excellence

Pennsylvania renovation reveals arcing wire in wall “Without the AFCIs, the faulty wiring may not have been discovered for some time and worse, could have caused a fire in the wall…”

•Home built in 1979 in Hampton Township, PA

•Homeowner chose to do a significant

renovation in June of 2001

•Upgraded electrical service to include AFCI’s

•Kitchen AFCI tripped

•Troubleshooting revealed stripped conductor

in kitchen wall

“As a result, I’m now a big fan of AFCI breakers

and would recommend them to anyone as

original or replacement equipment. Why take

a chance? “

80 years of excellence

AFCI stops fire hazard from stapled wire “Fortunately, the wires running up out of the panel in the garage, they found the issue…”

•Home run from Electrical panel

inadvertently stapled in wall

•AFCI Tripping identified issue before other

damage could occur

Effective operation of breaker, coupled with

good troubleshooting by electrical

contractor, eliminated hazard.

80 years of excellence

AFCI detects damaged NM Insulation Damage to the cable feeding the master bedroom, exposed by the AFCI. •AFCI feeding the master bedroom

receptacle outlets began tripping 3 years

after renovation

•12-2 cable was stapled to a floor joist using

cable staples like the ones in the photo

•Outer sheath indicated a hammer mark

•Cable sheath removed to reveal the hot and

neutral wires had shorted, there was

charring inside the outer sheath.

Fire hazard was discovered only because

the Arc Fault Circuit Interrupter was able to

detect the short in the cable.

80 years of excellence

Arc Fault Breakers:

worth it or just another government imposed rule? Idaho code requires new homes be equipped with arc fault breakers in every bedroom.

•Arc Fault breaker intermittently tripping

•Troubleshooting techniques enabled

contractor to narrow it down to the damaged

wire

•Wire had been struck by a finish nail in a

closet rod holder

•Nail piercing was causing a small arc

between the wire and the nail.

“Having the arc fault breaker installed

certainly helped to prevent any damage to

the home and its occupants.”

80 years of excellence

Contractor Careless “Fix” “My wife and I are very lucky that I stumbled onto the problem. What if we were away and a fire had started? We could have lost the house, or worse, what if we had been at home asleep?”

•73 year old home upgraded to 200Amp service with AFCIs on every

circuit

•At the end of the installation, contractor told homeowner that one

of the AFCI’s kept tripping, but he “fixed” the problem

•Ceiling light in a bedroom was out and new bulb immediately blew

out

•Homeowner discovered the fixture had a threaded porcelain socket

that loosened over time allowing the socket to rotate and the hot

and neutral wire to twist near where the insulation was stripped

•There is no question that arcing was happening because of the

missing pieces of wire, bubbled and retracted insulation, charred

wallpaper, and small bits of copper sprayed around.

•Homeowner then discovered contractor had replaced the tripping

AFCI with a conventional breaker.

“Our electrical contractor’s “fix” was to replace the

AFCI protecting that circuit with a conventional breaker.

I think he missed the point.”

80 years of excellence

Decorative lamp caused fire hazard An AFCI detected a series arc in a lamp before any damage could be done.

•Resident of an apartment complex experienced

intermittent tripping on one of the AFCI breakers

•Electrician discovered arcing between the light

bulb and socket of a decorative lamp.

Combination AFCI’s detect Series Arcs in a circuit

to protect against faulty electrical devices.

80 years of excellence

Ceiling Mounted Light Fixtures Recalled by Thomas Lighting

Due to Fire and Shock Hazards Thomas Lighting has received 11 reports of defective fixtures which resulted in the home’s Arc Fault Circuit Interrupter tripping.

•Name of product: Thomas Lighting ceiling flush mount light

fixtures

•Units: About 83,750

•Manufacturer: Thomas Lighting, of Elgin, Ill; part of Philips

Consumer Luminaires Corporation, of Elgin, Ill.

•Hazard: The fixture's socket wire insulation can degrade, leading

to charged wires becoming exposed, causing electricity to pass to

the metal canopy of the fixture. This poses a fire and electric shock

hazard to consumers.

•Incidents/Injuries: Thomas Lighting has received 11 reports of

defective fixtures which resulted in the home's Arc Fault Circuit

Interrupter (AFCI) tripping. No injuries have been reported to the

firm.

AFCI breakers detect faulty light fixtures which are

determined to be hazardous.